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Asthma, Isocyanates and The Group Authority Licence
the Home Office has granted a Group Authority Licence (GAL) allowing BOHS Members who belong to the Faculty of Occupational Hygiene permission to use sampling media containing 1,2-MP for the purposes of isocyanate monitoring to MDHS25/4. This is a key benefit of BOHS Membership as non-licenced hygienists cannot offer this service.
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This is essential reading for those using MDSH25/4
On 4th November 2020 the HSE published statistics (https://www.hse.gov.uk/ statistics/causdis/asthma.pdf) on workrelated asthma in Great Britain for 2019. The data suggest that the rate of increase of new cases per year continues to rise, continuing a 4-year trend.
Each year there are an estimated 17,000 new cases of self-reported “breathing or lung problems” caused, or made worse, by work. The most common cited causes of occupational asthma by chest physicians continue to be isocyanates and flour/grain. This article focusses on the former.
The legal framework for protecting workers’ health is enshrined in The Control of Substances Hazardous to Health (COSHH) Regulations. Employers are required to assess the risks to health from isocyanates, and put in place appropriate control measures. As the target organs are the lungs the most significant route of exposure is by inhalation. A fundamental part of the legallyrequired risk assessment is the measurement of exposures by inhalation. This requires the generation of valid data from workers’ breathing zones, and the comparison of these exposure measurements to Workplace Exposure Limits (WELs).
Those of you reading this who are occupational hygienists will recognise the above approach as the standard way of working. As with any other substance, you would turn to the Method of Determination of Hazardous Substance (MDHS) series of HSE Guidance Notes for information on approved, validated methods for carrying out such exposure measurements. This would identify MDSH25/4 as the method of choice. Therein lies the problem, because MDHS25/4 is unique!
MSHS25/4 is the only sampling method in the series that requires the use of a substance classified as a drug under Schedule 1 of the Misuse of Drugs Regulations 2001. This substance, 1-(2-methoxyphenyl) piperazine (‘1-2MP’), can only be legally used by persons working under a Home Office licence – and only then if the work is carried out in strict accordance with the conditions laid down in the licence.
Alternative sampling methods are available for isocyanates, however, they have drawbacks. They typically fail to measure the total reactive isocyanate group (TRIG) concentration necessary for direct comparison against the WELs. Hence MDHS25/4 remains the most appropriate method for measuring worker exposures and the method recommended by the HSE.
The health of workers would clearly be compromised if MDHS25/4 could not be used for the purposes of risk assessments. For this reason, The Home Office carries out audits on BOHS to ensure the Licence conditions are being met. The conditions are stringent and require 1,2-MP to be stored, used, and transported with similar management controls to other controlled drugs. BOHS is required to report annually to the Home Office on the safeguards put in place to ensure the conditions are met, together with information on quantities used. All incidents and issues are reported to the Home Office, who have the option of carrying out their own investigations.
All of the GAL conditions are embodied in the BOHS Standard Operating Procedure (SOP) which is accessible from the BOHS website. The SOP does not give details of how to carry out sampling. This is provided by MDHS25/4. However, following the SOP ensures compliance with the GAL. All Members must strictly comply with the SOP to avoid the potential revocation of this licence.
BOHS member orders and receives sampling media from authorised labaratory
Sampling media returned to issuing laboratory with reacking number (or by hand ibtaining written receipt.)
BOHS member ensures secure chain of custody during storage, transport and usage
Sampling media used for MDH525/4 survey
NO
Complete exemption record detailing quantities of media for destruction All sampling media used?
YES
As such a revocation would put workers’ health at risk, and take away a key Membership benefit, any non-compliance with the SOP will be investigated by the FOH Committee and actions taken as necessary.
All those operating under the GAL automatically accept the following Condition of Use: It is a Condition of use of the Group Authority Licence that all Members who carry out work under this Licence grant permission for the issuing laboratories to supply BOHS with data on the quantities of 1,2-MP received and returned. These data will be used solely for the purposes of verifying data supplied by the Member in any end-of-year audit, and to obtain data on total member usage. The latter is a requirement of our Home Office Licence. This Condition will apply to all work carried out from 1 January 2021.
The BOHS annual report to the Home Office is submitted by the end of January and relates to data from the previous year. It is important that if you have used MDHS25/4 you declare this usage on the BOHS website. If selected for full audit, the information provided must be complete and accurate. The above Condition of use will allow future end-of-year audits to include the scrutiny of laboratory records of sampling media supplied to Members, and of subsequent returns. This higher level of scrutiny will provide the Home Office with evidence of continuous improvement and assist in the GAL application for renewal required later this year. It is essential that all orders for sampling media containing 1,2-MP are in the name of the Member leading the survey who will take responsibility for all aspects of the work and the Chain of Custody. Maintaining a secure Chain of Custody from receipt of sampling media through to tracked dispatch is a key condition of the GAL. When working with 1,2-MP I always mentally breathed a sigh of relief when the receiving laboratory confirmed receipt of samples as it was then officially “off my patch”. This is a responsibility that cannot be taken lightly.
The audit of Member returns just completed has shown that some requirements of the SOP are being misunderstood. These are clarified below.
Some Members who do not utilise all of the sampling 1,2-MP media place the remainder into stock for future use. This is not permitted by the SOP. All such media must be returned to the issuing laboratory – either for analysis if used, or for destruction if not. Where unused media are returned for destruction, the quantities must be noted in an Exception Record which would be required for review if selected for audit.
It is important that the Chain of Custody of the sampling media is secure. This requires the documenting of the despatch tracking number as evidence in documentation returned for audit. The SOP allows for non-Members to assist in the survey providing they work under close supervision of a Member and are trained in the requirements of the SOP. The audit documentation should detail how this is achieved.
In practice, the requirements of the SOP have not changed. The above comments provide clarification only. However, what will change is the auditing process. All 1,2-MP sampling media supplies and returns will be verifiable by the issuing laboratories. It is therefore important to ensure that all usages of MDHS25/4 are declared, and that the data supplied are accurate. Your co-operation is essential to ensure retention of the GAL. Losing this key Member benefit is not an option.
